Alston & Bird Consumer Finance ABstract

An Ominous Development in CFPB Supervision

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  A&B ABstract: The CFPB’s Bulletin 2021-01 released on March 31, 2021 announced changes to the Bureau's type of communications.  Does this bulletin suggest a desire of the CFPB to use the examination process for purposes that go beyond the Dodd-Frank Act? The Dodd Frank Act The Dodd-Frank Act grants the CFPB authority to require reports and conduct examinations of certain covered persons, including nonbanks and banks with greater than $10 billion in assets. However, the CFPB’s … [Continue reading] about An Ominous Development in CFPB Supervision

The District of Columbia Continues to Fight the “True Lender” Rule in Court

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Money

A&B ABstract: Innovative partnerships between banks and nonbanks have expanded lending services to consumers and small businesses. These partnerships, known as marketplace lending arrangements, offer non-traditional loan products to consumers … [Continue reading] about The District of Columbia Continues to Fight the “True Lender” Rule in Court

The CFPB is Sending Mixed Messages on COVID-19 Flexibility

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A&B ABstract: The CFPB’s inconsistent statements about the need for flexibility to address the pandemic suggest a deeper game afoot.  CFPB warns that continued COVID flexibility for financial institutions is not prudent… On March 31, 2021, the … [Continue reading] about The CFPB is Sending Mixed Messages on COVID-19 Flexibility

Avoiding Pitfalls During Post-Pandemic Government Investigations

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Global Expenses

As the country begins to emerge from the COVID-19 pandemic and the U.S. economy gets back on track, banks nationwide should expect their activities to come under government scrutiny. The impacts of the coronavirus have touched every corner of the … [Continue reading] about Avoiding Pitfalls During Post-Pandemic Government Investigations